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Manufacturers & importers of products

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Manufacturers of finished goods (so-called "articles") containing chemicals need to comply with specific duties under REACH. But registration is not necessary for these in most cases. The same applies to importers (from outside EU).

An article in terms of REACH is any object that has been given a specific shape, surface or design so that it can be used for a specific purpose, where the form and design is more decisive for fulfilling its purpose than its chemical composition.

Examples are:

  • IT devices
  • Household appliances
  • Wireless or radio devices
  • Toys
  • Textiles
  • Packaging

Special obligations

Nevertheless, in some cases an article requries action under REACH:

  1. If any of the substances included in the candidate list of SVHC (substances of very high concern) is present in a an article with more than 0.1% weight by weight,
    - then instructions on safe use shall be provided to next part of supply chain.

  2. If any of the substances included in the candidate list of SVHC (substances of very high concern) is present in a an article with more than 0.1% weight by weight, and and if the article is produced or imported into EU with more than 1 tonne per year per producer or importer,
    - the article has to be notified to the ECHA agency,
    - as long as it cannot be demonstrated that exposure to humans and environment can be excluded during normal conditions of use, including disposal.

    - A separate notification should be submitted to ECHA for each article that makes up a complex product, when more than 0.1% of the weight of this article was made up of a SVHC. Therefore several notifications are required for some complex products.

  3. If chemicals are released from articles intentionally during normal and reasonably foreseeable conditions of use,
    - then this has to be registered according to the normal rules, if they are produced or imported in quantities exceeding 1 tonne/year per producer or importer.

  4. If a product contains a non-registered chemical.

SVHC identification and determination

You do not know whether your products contain SVHC above allowed concentrations and quantities? Then please follow the link to our SVHC evaluation.

Importers of articles

Please click here for a special guideline for importers, issued by Danish authorities, with contributions of, among others, Eurofins Product Testing A/S.

Consulting services

For consulting on above issues and design of any test program, please contact

Mr. Kim Holm Baekgaard, Phone +45 70 22 42 76 in Denmark

or Jody Yam, Phone +852 263 632 33 or +86 131 439 879 87 and Chris Zhang +86 21 61819146 in China